Recently the Office of Management and Budget (OMB) issued updates to Uniform Guidance 2 C.F.R Part 200 which become effective November 12, 2020. The revised guidance if applicable for awards issued after this date. Previous awards are subject to the existing uniform guidance provisions. The UG is primarily directed to federal agencies. OMB expects all agencies to provide their guidance to the research community by November 12th. More information will be communicated as guidance becomes available from our sponsoring agencies and national organizations.
Here are some of the key points of new guidance from OMB:
- New definitions for “budget period” and “period of performance” are used throughout the UG update.
- Publication costs may be charged during award closeout (after the end of the formal period of performance).
- A new sentence was added stating pre-award costs “musts be charged to the initial budget period of the award, unless otherwise specified by the Federal awarding agency.” Awards issued under expanded authorities are more flexible. A new section states that “costs must be incurred during the approved budget period.”
- The number of days to submit final financial and final performance reports was amended from 90 days to 120 days. Additionally, liquidation of all financial obligations was extended to 120 days.
- Agencies are now allowed to terminate awards without cause.
- Any entity, whether they have ever had a Federally negotiated F&A rate, may use the 10% de minimus indirect cost rate without the need to provide documentation.
More detailed information on the Uniform Guidance changes is available on the following links:
https://www.cogr.edu/sites/default/files/UG%20Readiness%2010-19-20%200700FINAL.pdf
https://grants.complianceexpert.com/sites/grants/files/advisory_files/2020-17468_0.pdf